`
`Patent No. 6,896,773
`IPR2014-00726
`
`
`_____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_____________________
`
`THE GILLETTE COMPANY,
`Petitioner
`
`v.
`
`ZOND, LLC
`Patent Owner
`
`_____________________
`
`Inter Partes Review Case No. IPR2014-00726
`
`Patent 6,896,773 B2
`
`_____________________
`
`
`
`AFFIDAVIT OF ETAI LAHAV IN SUPPORT OF PATENT OWNER’S
`MOTION FOR PRO HAC VICE ADMISSION
`
`I, Etai Lahav, being duly sworn and upon oath, hereby attest to the
`
`following:
`
`i.
`
`I am a member in good standing of the New York Bar, as well as the
`
`following Federal Courts:
`
`a) U.S. District Court for the Eastern District of New York;
`
`b) U.S. District Court for the Southern District of New York; and
`
`ZOND 2001
`
`
`
`c) U.S. District Court for the Eastern District of Texas.
`
`Patent No. 6,896,773
`IPR2014-00726
`
`
`ii.
`
`I have not been suspended or disbarred from practice before any court or
`
`administrative body.
`
`iii.
`
`I have never had an application for admission to practice before any
`
`court or administrative body denied.
`
`iv. No sanction or contempt citation has been imposed against me by any
`
`court or administrative body.
`
`v.
`
`I have read and will comply with the Office Patent Trial Practice Guide
`
`and the Board’s Rules of Practice for Trials set forth in part 42 of the
`
`Code of Federal Regulations.
`
`vi.
`
`I will be subject to the USPTO Rules of Professional Conduct set forth
`
`in 37 C.F.R. §§ 11.101 et seq. and disciplinary jurisdiction under 37
`
`C.F.R. § 11.19(a).
`
`vii. Other than presently applying to appear Pro Hac Vice before the Office
`
`in connection with the Inter Partes Review proceedings of the patents
`
`listed below in section ix, I have not applied to appear Pro Hac Vice
`
`before the Office in any other proceeding in the last three years.
`
`viii.
`
`I am an experienced litigation attorney, with experience in many
`
`litigations involving patent infringement in District Courts across the
`
`country, including experience with fact and expert document and
`
`
`
`2
`
`ZOND 2001
`
`
`
`deposition discovery, claim construction, Markman hearings, motion
`
`Patent No. 6,896,773
`IPR2014-00726
`
`
`practice, trials and hearings, and investigations before the International
`
`Trade Commission.
`
`ix.
`
`I am counsel for Patent Owner Zond, LLC, the plaintiff in related on-
`
`going litigations in which U.S. Patent Nos. 6805779, 6806652, 6853142,
`
`7147759, 7604716, 7808184, 7811421, 6896775, 8125155, and 6896773
`
`are and were asserted by the Patent Owner. I am familiar with the
`
`subject matter at issue in this proceeding as a result of my representation
`
`of Zond, LLC, in the related litigation, including the prior art that
`
`Petitioner presents in this proceeding, as well as issues of claim
`
`construction.
`
`
`
`Date: November 11, 2014
`
`
`
`
`
`/Etai Lahav/
`Etai Lahav
`RADULESCU LLP
`Empire State Building, Suite 6910
`350 Fifth Avenue,
`New York, NY 10118
`etai@Radulescullp.com
`
`
`
`3
`
`ZOND 2001
`
`
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